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TMI Blog2017 (1) TMI 847X X X X Extracts X X X X X X X X Extracts X X X X ..... proceedings. In fact, even the basis of the present proceedings i.e. the reasons recorded in support of the notice does not support, even remotely, any submission to allege failure on the part of the respondent assessee to truly and fully disclose all necessary facts for assessment. Therefore, as correctly held by the CIT(A) and the Tribunal, the reopening notice dated 24th September, 2003 would ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the assessee to disclose fully and truly all material facts necessary for the assessment and the income of assessee has escaped assessment? 3. The impugned order records the fact that the respondent assessee had originally filed its Return of Income on 28th November, 1997. Thereafter, on 30th March, 1999 the respondent assessee filed a revised Return of Income. On 25th February, 2000, the As ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... wed of ₹ 74.51 lakhs. The aforesaid resulted in escapement of income by reasons of the failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment of income. 5. Thereafter, by an assessment order dated 30th December, 2003 passed under Section 143(3) r/w Section 147 of the Act rejected the assessee's challenge to the reopening and conf ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... te that there is any failure on the part of the respondent assessee to truly and fully disclose all material facts necessary for the assessment. It further records that that all the facts necessary for assessment were fully and truly disclosed by the respondent assessee in its revised return of income filed on 30th March, 1999 in respect of all the three issues. Thus, the appeal of the Revenue was ..... X X X X Extracts X X X X X X X X Extracts X X X X
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